J RECEIV ED U.S. E. P..A. By Appeal Number...Mail code 11 03M ; Washington, D.C. 20460-0001 Date: August 13,2013 ; PETITION SEEKING BOARD REVIEW OF UNDERGROUND INJECTION CONTROL PERMIT

J

RECEIV ED US E PA

Clerk of the Board US Environmental Protection Agency Environmental Appeals Board 1200 Pennsylvania Avenue NW E~JVIR APPEALS BOARD Mail code 11 03M Washington DC 20460-0001 Date August 132013

PETITION SEEKING BOARD REVIEW OF UNDERGROUND INJECTION CONTROL PERMIT MI-009-2D-0217

I am requesting board review ofthe Regions actions on the above pennit for the following reasons

1) Tenninology used in Responses 1 4 7 9 10 and 11 include the phrase should which suggests that no final scientific detennination has been made in regard to these issues and leaves the matter open to interpretation at the discretion of the regulatory agency This includes the question of contamination of water wells in the vicinity and the contamination of local waterways including the Jordan River and Lake Michigan and the Great Lakes aquifer The word should in regulatory documents is open-ended and vague and indicates the need for more study

2) Response 4 discusses EPAs finding about the environmental safety of injection wells but does not cite the finding The next paragraph refers to the penneability of rock layers but does not cite the geological evidence to support the claim It also mentions the 40 feet of Bell Shale above the Dundee limestone to indicate that those 40 feet will protect the injected waste from drinking water I am requesting scientific and geological evidence to support this claim and to constitute proof that the claim is valid

3) Responses 2 and 5 are in reference to seismic activity stating that there are no documented cases of seismic activity in Antrim County However a fault line has been identified extending from Antrim County through Otsego according to research by James Wood MTU and William Harrison WMU (December 2002) and the US Geological Survey recommends an assessment of the absence or presence of faults to reduce risk of leaks from underground wells I am questioning the wisdom of claiming no seismic activity when a fault line is present There is no proof there will never be activity and there is always a possibility of occurrence

4) Response 6 is in regard to the designation of the Jordan River as a Wild and Scenic River and notes that well drilling and brine injection is pennitted under the law I dont dispute that claim I propose that the current regulations are irresponsible and threaten our most precious resource water The headwaters of the Jordan River and its watershed in which I reside and in which the proposed injection well is located feed the Jordan which flows into Lake Charlevoix and is connected to Lake Michigan the significance of which cannot be overstated Surely the EPA has an interest in protecting the Great Lakes

5) 15 16 and 17 is that no laws wells from drinking water wells and no

injection wells may leak The fact that no does not justify lack of regulation Conversely isnt the burden the individual or that seeks to engage in risky behavior that us that the wells wont leak the Response notes owners are responsible for clean-up due to contamination Why is

it is so

In permit should be declared invalid Furthur of the ramifications injection of brine solution is imperative allows this

Sincerely

Email

RESPONSE TO COMMENTS

Date JU L 2 5 2013

REGARDING UNDERGROlJND INJECTION CONTROL (DIC) PERMIT MI-009-2D-0217 ISSUED TO CHEVRON MICHIGAN LLC FOR THE STRATTON 16-4 INJECTION WELL IN ANTRIM COUNTY MICHIGAN FOR THE PURPOSE OF NONCOMMERCIAL DISPOSAL OF OILFIELD BRINE FROM PRODUCTION WELLS OWNED OR OPERATED BY CHEVRON MICHIGAN LLC

Introduction

Tbis response to comments document is a comprehensive response that responds to all comments received by United States Environmental Protection Agency (EPA) Region 5 for this permitting action Region 5 previously issued a final pennit decision on this matter on August 202012 however the Environmental Appeals Board (EAB) issued a remand relating to this pennit in In re Chevron Michigan LLC UIC Appeal No 12-01 (EAB 2013) on March 52013 The EAB remand allowed Region 5 to reissue this final permit along with a comprehensive response to all comments The EAB stated in its remand order on pages 17-18

This Remand Order does not reopen the public comment period After the Region middot completes its actionon remand anyone dissatisfied with the Regions actions on remand must file a petition seeking Board review in order to exhaust administrative remedies pursuant to [40 CFR sect 12419(1)(2)]1 Any such petitions shall be limited to those issues addressed by the Region on remand or raised by or in connection with the remand procedures No new issues may be raised that could have been raised but were not raised in the present appeal

Region 5 is providing this response in accordance with Section 12417 of Title 40 of the Code of Federal Regulations (40 CFR sect 12417) which requires EPA to issue a response to comments at the time it issues a final permit decision That response must (1) briefly describe and respond to all significant comments raised during the public comment period and (2) specify whiCh provisions if any of the draft decision have been changed and the reasons for the change In addition EPA must include in the administrative record any documents cited in the response to comments and make the response to comments available to the public

1 EPA recently issued a rule revising part 12419 which became effective on March 26 2013 Anyone filing a

petition for review upon the Regions completion of actions on remand after March 26 2013 should follow the

latest version of sect 12419 in preparing a petition for review See Revisions to Procedural Rules To Clarify Practices

and Procedures Applicable in Permit Appeals Pending Before the Environmental Appeals Board 78 Fed Reg 5281

(Jan 25 2013) Additional information on this change is available on the Boards website at

http yosem iteepa govoaEAB _Web_Docket nsfGeneral+1 nformationRegu lations+Govern ing+Appeals Open D

ocument

Background

The scope of the Federal Underground Injection Control CUIC) regulations is limited to the determination of the soundness ofconstruction and operation of inj ection wells as they relate to the protection of all underground sources of drinking water (USDWs) A USDW is an aquifer or its portion which contains less than 10000 mgl of total dissolved solids

In this case the proposed well will be drilled to a depth of 1535 feet below ground surface into the Dundee Limestone The top of the injection zone is at 1343 feet The base of the lowermost USDW has been identified at a depth of 1301 feet below ground surface and is separated from the top of the Dundee Limestone injection zone byapproxirnately 42 feet of sedimentary rock strata This rock strata consists of very lowpermeabilityrock and will prevent vertical migration of fluid In addition all well casing strings are adequately cemented to preclude the movement of fluids into and between USDWs due to injection operations

As additional protection injection will take place through tubing which is set within the steel casing A packer will be set at the bottom of the tubing to seal off the space between the casing and tubing which will be filled with a liquid mixture containing a corrosion inhibitor and will allow the pressure in the space to be monitored The pressure in the space between the tubing and casing (annulus) will be tested initially after the cbmpletion of the well to ensure that the well has mechanical integrity and monitored weekly thereafter to ensure that the well maintains mechanical integrity Any loss of annulus fluid is monitored at least quarterly If the well should fail a mechanical integrity demonstration then the well will be shut down until corrective actions have been taken and the well has been brought back into compliance Any work performed on the well which requires the moving andlor removal of the tubing or packer must be followed by a mechanical integrity test before authorization to resume injection will be given Under permit conditions the injection pressure will be limited to ensure the safe operation of the well and monthly reports of pressure and flow rates must be submitted to our office for review If despite these safeguards contamination of drinking water occurs the operator is fully liable for providing alternate soUrces of drinking water In addition some operators may be willing to work with local residents to respond to problems

Oilfield brines may contain various amounts of hydrocarbons such as benzene ethylbenzene toluene xylene naphthalene polycyclic aromatic hydrocarbons Fluids brought to the surface in connection with conventional oil and natural gas production have been exempted from the definition of hazardous waste under the Resource Conservation and Recovery Act under Title 40 of the Code of Federal Regulations (40 CFR) sect 2614(b )(5) Such fluids are naturally occurring fluids that are separated from the oil andlor gas and then returned to the rock formations from which they originated or to a deeper rock formation via Class II injection wells The UIC program protects USDWs from these fluids by regulating injection wells

2

as such a manner so as to

determined would

issues which

a basis for that it is appropriate

did not

vu a final permit to Chevron to issue a

permit to II injection well EP A is Michigan shown at the top of document

Comment 1

L-OmnleIJlter identified that contamination of water wells occurred other States as the result of injection well and brought up an tgtVArrl

a documented case of an injection well contaminating an underground source drinking water began It is however that fluid came to

III the area wells were into a zone which oecarrle

VA- shy fluid other wells that were not properly constructed or identified during review However was no documented contamination an underground source of drinking water by the injection fluid to access a onterent zone with more CatmC1T injection rates were State

injection wells were by

circumstances and Michigan and at this well are different than in Texas which through conduits geology of IS

across the state that strata are logs or formation nearby wells were to the area EPA

data the hundreds of wells have of Michigan such as The Hydrogeologic Atlas of

to be geologically suited for II wells within the area of review are properly constructed or

by our office LVltvLHvl

migration any into nearby drinking water wells from of injection

previously well will be the

between Asa on

-VLLUVLltCVJ raised concerns about the recentseisrnic events in Youngstown Ohio where 1210w magnitude CgtllLlv events occurred as a result of Class II injection well activities

3

(

Response to Comment 2

The Northstar Class II injection well in Ohio was drilled at a depth of9192 feet below surface into the Precambrian Period rocks The evidence gathered by Ohio DNR regulators and geologists suggests that the fluid from a deeply drilled injection well intersected an unmapped fault in a near-failure state of stress causing movement along the fault In the case of the MIshy009-2D-0217 proposed well the injection well will be drilled to a shallower formation into the Devonian Period rocks at about 1535 feet below surface In addition based on data available from several decades of experience regulating similar injection wells there are no documented cases of seismic activities occurring in Antrim County

Comment 3

Commenter requested that at a minimum a gamma ray compensated density-neutron and resistivity logs be required for all new Class II disposal wells in Michigan


In accordance with 40 CFR sect 14622(pound)(2)(i) (B) and (ii)(A) only the following logs are required under our current regulations cement bon~ temperature or density log after the casing is set and an electric porosity and gamma ray log before the casing is installed These logs are required for all newly drilled Class II disposal wells in areas where the lithology has not been determined

Comment 4

Commenter expressed concerns regarding the depth of the inj ection well and contamination of commenters drinking water well or future drinking water wells drilled on cornmenters property


Underground injection wells are designed with multiple safeguards to prevent minimize and internally contain leaks within the well Injection wells are constructed with il1ultiple steel casings cemented into place Injection takes place through tubing located at the center of the innermost steel casing A device called a packer seals off the bottom of the tubing and the space between the innermost steel casing and tubing (called the annulus) is filled with a fluid containing a corrosion inhibitor To assure that no leaking occurs in the well the pressure within the annulus space is tested after the well is completed and then re-tested periodically If this test fails the well is shut down immediately and the cause of the leak is isolated and repaired Once shut down a successful pressure test mustbe demonstrated before EPA will allow the operator to resume well injection The injection well will be constructed and operated in such a manner so as to confine the injected fluids to the permitted interval and prevent the migration of any fluids into and between the Underground Sources of Drinking Water (USDW) As a result there

(

should be no connection between the injection well and nearby drinking water wells or surface

4

waters An EPA pennit an injection well conveys to inject fluids finding that the construction of well is that injection into the environmentally LLC is fully responsible for is protected from COJ1tamlJ1atlOn

Federal Regulations the depth of the injection well to a depth aeeDer then 10wennost known USDW is to fluid the USDW The

AVmiddotUu above the proposed There is

Shale separating injection zone from the lowermost Bell Shale is a high density rock lVlHWUV will the injected fluid to the f) v(V-t

permitted injection zone n rnn indicates that drinking water ~ wells in of feet and 200 feet

grolli1d between the proposed the drinking water aquifer

by resIdents m the area

J oj1~

rU arolli1d the well These rock upward movement of fluid to the lowennost ~trvshy

USDW local ~

how EPA determines that the confming are ofknown

Drillers logs fonnation records from nearby wells and the Atlas of Michigan were used to review from both confining zone and injection zone The geology of Data Iuv~

wells of the Shale is impenneable and serves as an

effecti ve confining zone over most of the of Michigan is no documentation Although fractures are much smaller than ~the a

UUIVHlCIAvaJI) disqualify it as an adequate confining zone a

well below needed to fracture rock

5

formation in the confinipg and injection zones The draft permit requires Chevron to monitor the injection pressure ona weekly basis and report to EPA on a monthly basis Injection pressures above th permitted maximum injection pressure would be a violation of the conditions of the permit Additional operating conditions contained in the draft permit prohibit the fracturing of the confining zone Violation of any permit condition would subject Chevron Michigan LLC to an enforcement action by EPA

Comment 6

Commenter expressed concerns regarding contamination of the Jordan River from the proposed brine injection and Commenter identified the Jordan River as designated Wild and Scenic


As part ofEPAs standard procedure for reviewing permit applications we verify that the well is not within one-quarter mile of a Federally-designated Wild and Scenic River The Jordan River is located over 2 miles from the proposed injection well and will not be affected by the injection ofb~ine at this well location In addition the Jordan River is not Federally protected the State ofMichi~an has designated it as a Natural River State law requires that Michigan Natural Rivers be protected to a distance of 400 feet from each banle In addition to a permit from the EPA operators in Michigan must also receive a pennit from the Michigan Department of Environmental Quality (MDEQ) The MDEQ field checks all well locations before issuing permits Before receiving an MDEQpermit the well location must conform to MDEQ requirements

Comment 7

Commenter expressed concerns regarding the contamination of the drinking water aquifer do to the injection of fluids from the proposed welL


Underground injection wells are designed with multiple safeguards to prevent minimize and internally contain leaks within the welL Injection wells are constructed with multiple steel casings cemented into place Injection takes place through tubing located at the center of the innermost steel casing A device called a packer seals off the bottomofthe tubing and the space between the innermost steel casing and tubing (called the annulus) is filled with a fluid containing a corrosion inhibitor To assure that no leaking occurs in the well the pressure within the annulus space is tested after the well is completed and then re-tested periodically If this test fails the well is shut down immediately and the cause of the leak is isolated and repaired Once shut down a successful pressure test must be demonstrated before EPA will allow the operator to

6

resume

TlPrnJ drinking water wells and streams

well conveys permission to inject fluids based on

leaks can happen due to a loss

zone The injection well will and

any fluid leaks out into the drinking water

operated in a manner so as to the inj ected fluids to the permitted prevent the

Water (USDW) a

nearby drinking water

injection ensuring the

Safe Drinking 307 can

Comment 8

into and between the Underground Sources of

== be no connection between permit for an injection well conveys

construction and operation of the

n1-tPI1 from contamination due to

lvHJlltCLH Department ofEnvironmental vmiddotuumiddotmiddotu1J any contamination due to

-- gtLu- VVJJ~U UJVJJ of Cormnenter s r-1

constructed and operated in such a manner

permitted interval In addition part of the if any on any cultural or historical

Michigan LLC contacted the Michigan

and submitted ipformation for the proposed

15 2012 letter from SHPa to USEP A the of are affected from the proposed

As described

injection well project

Michigan concluded inj ection well

+++

Cormnenter UVlUHlU Jordan River Lake ~u~~ Lake Michigan and concerns

well

and operated in such a manner so as to

This will prevent the migration

streams and rivers As a result there should no it

7

finding that the construction and operation of the well are such that injection will be environmentally safe In addition surface spill prevention and remediation are regulated by the Michigan Department of Environmental Quality (MDEQ) The MDEQ also csues permits for underground injection wells within the State of Michigan The Michigan administrative rules contain requirements regarding well site maintenance and clean-up

Comment 10

Commenter expressed concerns regarding the contamination of the drinking water aquifer due to the injection of fluids from the proposed well


Underground injection wells are designed with multiple safeguards to prevent minimize and internally contain leaks within the well Injection wells are constructed with multiple steel casings cemented into place Injection takes place through tubing located at the center of the irmermost steel casing A device called a packer seals off the bottom of the tubing and the space between the irmermost steel casing and tubing (called the armulus) is filled with a fluid containing a corrosion inhibitor To assure that no leaking occurs in the wellthe pressure wit4ill the armulus space is tested after the well is completed and then re-tested periodically If this test fails the well is shut down immediately and the cause of the leak is isolated and repaired Once shut down a successful pressure test must be demonstrated before EPA will allow the operator to resume well injection Although small leaks can happen due to a loss of seal between the packer and the well casing this does not mean that any fluid leaks out into the drinking water aquifer because the fluid will go into the injection zone The injection well will be constructed and operated in such a marmer so as to confine the injected flUids to the permitted interval and prevent the migration of any fluids into and between the Underground Sources of Drinking Water (USDW) As a result there should be no cormection between the injection well and ~

nearby drinking water wells An EPA permit for an injection well conveys permission to inject fluids based on EPAs finding that the construction and operation of the well is such that injection into the well is environmentally safe Chevron Michigan LLC is fully responsible for ensuring the groundwater is protected from contamination due to injection The EPA under the middotI~ Safe Drinking Water Act and the Michigan Department of Environmental Quality under Act W11~ In u 307 can require ownersoperators to clean-up any contamination due to injection andor supply) It rtt~1J- Imiddot alternative drinking water sources I dtllJf

1ft- ~ 1 Comment 11

Commenter identified the Jordan River Lake Charlevoix and Lake Michigan and concerns of contamination of these surface waters from the proposed injection well project

8

above the injection injected fluids to

ruptgtrgt USDWs as well as

COJJJl(~CLJlOn between the injection well permit for an

construction and nltln

environmentally safe In addition of

injection wells within -VA1ULlUl requirements regarding well

operated in a manner so as to This will prevent and rivers As a

drinking water wells conveys permission to

the well are such that prevention and remediation are by the (MDEQ) The MDEQ also permits for

Michigan The Michigan U-ULUU

UHHvHwnbullbull v and clean-up

expressed concerns contamination waters

injection wells are multiple safeguards to nrpP1nT HUUluuLo

contain leaks within the well wells are constructed VUf cemented into place Injection through tubing located at center of the

steel casing A device off the bottom of and the space innermost steel vULu1 the annulus) is

C0I1Ialmrlg a corrosion inhibitor no leaking occurs in within is tested vVLUIJJvLU and then gt0gt101gt0gt11

Once pressure test must

resume injection Although heltwf~en the jJu

and well casing this does not mean UHIlKlLIlg water aquifer Jvau)v the flUId will go into zone The injection constructed and

-1tgt in such a manner so as to VVLLLULV the injected fluids to ngt1rtY11TTpmiddotr1 interval and

migration of any between the Underground of Drinking (USDW) As a result connection between well and

AUi~uh water wells or EP A permit for an leCtlOn well conveys inject fluids that the construction operation of the well

(MDEQ) Issues

Michigan administrative requirements maintenance and VLu

9

clean-up Chevron Michigan LLC is fully responsible for ensuring the groundwater is protected

_~ from contamination due to injection The EPA under the Safe Drinking Water Act and the ~i ~ Michigan Department of Environmental Quality under Act 307 can require ownersoperators to

~ lclean-up any contamination due to mjection andor supply alternative drinking water sources

~ Comment 13 bull

Cornmenter asked if there was a permitted distance between drinking water wells and injection wells


The Federal Regulations for underground injection wells do not restrict the surface distance between an injection well and a drinking water welL Federal Regulations restrict the depth of the injection well to a depth deeper then the lowermost known USDW This is to insure that the

injected fluid does not migrate into the USDW The drinking water wells in the area of the proposed injection well are drilled to an average depth of between 40 feet to 200 feet The proposed top of the injection zone for the proposed well is located at 1343 feet below the ground surface There will be approximately 1000 feet of low permeability rock layers between the proposed injected fluid and the drinking water aquifer used in the area around the welL These

~ rock layers prevent movement of the ~jected fluid into the local drinking water wells

Comment 14

Cornmenter asked if brine disposal through injection wells is linked to seismic activity

Response to Comment 14 l

~ (Any seismic activity from disposal well injection would be caused by fracturing any of the rock (gt (formations surrounding the welL The draft permit for this well does not allow the fracturing of

any rock formation EPA has established the maximum permitted injection pressure for this well using the fracture gradient equation This equation uses a conservative estimate for the fracture gradient and establishes a maximum injection pressure well below the pressure needed to

fracture the rock formation in the confining and injection zones The draft permit requires Chevron to monitor the injection pressure on a weekly basis and report to EPA on a monthly basis Injection pressures above the permitted maximum injection pressure would be a violation

of the conditions of the permit Additional operating conditions contained in the draft permit prohibit the fracturing of the confIning zone Violation of any permit condition would subject Chevron Michigan LLC to an enforcement action by EPA

10

-VUllJcltvLcvL asked ifthere is a history of fluid andor radiation Lv wells

Michigan


Water Act was authorized in 1 and gave EPA

LOmTI1eI1lter asked to ~~middotUJ the vH~Hlval oresent in the

The Regulations 2 underground wells do not analysis for chemicals that

application melctlcm of noncommercial brine

Chevron wells originates within oil and rock JHULlVlhl and has a chemical make-up very to the ground water existing at

proposed welL contained that are to the operation are Special Condition A Operating

Monitoring Reporting Requirements of the draft by the Chevron chemical make-up Chevron

uvLUUL allow EPA to will be

the terms Violations of

The brine VU-AA

thesources In order

zone Injection a violation

not consistent

condition would subject to an

of the injected the

of the

11

)

Comment 17

Commenter expressed concerns regarding increased noise and vehicle traffic in the area of the proposed injection welL


EPA regulations at 40 CFR Parts 144 and 146 state the requirements and standards that a permit applicant must meet to have an undergrOlind injeCtion control (UIC) permit application approved These regulations deal primarily with the geologic siting well engineering operating and monitoring standards for deep injection wells Vehicle transportation and noise issues are not addressed by the UIC regulations and are outside the scope of the UIC permit process

Comment 18

Commenter requested that EPA order Chevron to monitor the water quality of Commenters drinking water well and plant foliage at Commenters property line to act as a barrier between the well site and Commenters property


EPA regulations at 40 CFR Parts 144 and 146 state the requirements and standards that a permit applicant must meet to have a UIC permit application approved These regulations deal primarily with the geologic siting well engineering operating and monitoring standards for deep injection wells There is no requirement for the permit applicant to test or monitor drinking

~ wat~r wells in the vicini~ of the pr~po~ed injection ~ell EPA cannot compel the permit applIcant to conduct testmg or momtonng oflocal drinkmg water wells as part of the penmt approval process for this proposed injection welL In addition there are no requirements in the

EPA regulations for the permit applicant to plant foliage as a barrier between the injection well and neighboring properties

APPEAL

In accordance with 40 CFR sect 12419 any person who filed comments on the draft permit or participated in the public hearing may petition EPAs Environmental Appeals Board for review of the final permit decision Such a petition shall include a statement of the reasons supporting review ofthe decision including a demonstration that the issue(s) being raised for review were raised during the public comment period (including the public hearing) to the extent required by these regulations The petition should when appropriate show that the permlt condition(s) being appealed are based upon either (l) a finding of fact or conclusion of law which is clearly erroneous or (2) an exercise of discretion or an important policy consideration which the Environmental Appeals Board should in its discretion review

The Environmental Appeals Board issued a remand relating to this pennit in In re Chevron Michigan LLC UIC Appeal No 12-01 (EAB 2013) on March 5 2013 arid provided that EPA

12

If BoardUS

Avenue Mail Code 1103M NW ==-=--== must

UVJlllUULUJ

UHU1Ui Room 3334 Washington DC 20004

AUG 2 7 2013 will it must confonn to the

This

along with a VVJeHjJV--0 comments n_vJHJ~U Order is attached The EAB

A of 17-18

public comment period the HHltshy

Protection you must submit a by====~==

sent

Environmental Appeals ugtLLUJ5VH DC 20460-0001

Appeals uvlt~u Avenue

request must arrive at the if

Signed and

lt EPA issued a rule revising part 12419 which became effective on March 26 2013 Anyone a

petition for review upon the completion of on remand after March 26 2013 should follow

latest version of sect 12419 in a for review See Revisions to Procedural Rules To Clarify Practices

and Procedures in Permit Appeals Before the Environmental Board 78 Fed 5281

ocument

13

5) 15 16 and 17 is that no laws wells from drinking water wells and no

injection wells may leak The fact that no does not justify lack of regulation Conversely isnt the burden the individual or that seeks to engage in risky behavior that us that the wells wont leak the Response notes owners are responsible for clean-up due to contamination Why is

it is so

In permit should be declared invalid Furthur of the ramifications injection of brine solution is imperative allows this

Sincerely

Email


Date JU L 2 5 2013


Introduction










ocument

Background





2


determined would

issues which


did not



Comment 1













between Asa on


3

(



Comment 3




Comment 4




(


4








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13


Date JU L 2 5 2013


Introduction










ocument

Background





2


determined would

issues which


did not



Comment 1













between Asa on


3

(



Comment 3




Comment 4




(


4








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

Background





2


determined would

issues which


did not



Comment 1













between Asa on


3

(



Comment 3




Comment 4




(


4








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13


determined would

issues which


did not



Comment 1













between Asa on


3

(



Comment 3




Comment 4




(


4








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

(



Comment 3




Comment 4




(


4








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13








J oj1~


USDW local ~







5


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13


Comment 6




Comment 7




6

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

resume







Water (USDW) a




Comment 8












As described



+++


well




7


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13


Comment 10





1ft- ~ 1 Comment 11


8























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13























(MDEQ) Issues


9




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13




~ Comment 13 bull






Comment 14







10


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13


Michigan











The brine VU-AA

thesources In order


not consistent


of the injected the

of the

11

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

)

Comment 17




Comment 18






APPEAL



12

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

If BoardUS


UVJlllUULUJ



This


A of 17-18



sent




Signed and





ocument

13

Documents

J RECEIV ED U.S. E. P..A. By Appeal Number...Mail code 11 03M ; Washington, D.C. 20460-0001 Date: August 13,2013 ; PETITION SEEKING BOARD REVIEW OF UNDERGROUND INJECTION CONTROL PERMIT